Comments on Bloom Energy proposal to replace fuel cells (DNREC, PSC)

SECURE AMERICA’S FUTURE ECONOMY, advocating smaller, more focused, less costly government since 1996 http://www.s-a-f-e.org/

January 21, 2019

Ms. Lisa Vest, Hearing officer
Department of Natural Resources and Environmental Control

Re: Regulation No. 1102 Natural Minor construction permit applications submitted by Bloom Energy to replace all fuel cells at the Red Lion and Brookside sites

The Bloom Energy applications were filed with DNREC’s Division of Air Quality on October 23, 2018, and a public hearing thereon was conducted on January 10, 2019. A summary of the information presented and relevant background information has been posted on our website. Bloom Energy proposes to replace fuel cells at QFCP power facilities,
1/21/19. [Access path: Secure America’s Future Economy – Blog – 1/21/19.]

Based on the foregoing, we would like to offer the following comments and request that they be appropriately reflected in the disposition of this matter:

1. Operation of the fuel cells results in sulfur and other contaminants in natural gas being trapped in desulfurization units, which must be periodically removed and disposed of. Bloom needs to disclose the volume of such waste that will be generated by the new fuel cells and the disposal procedures to be followed (and monitored by DNREC) Air emissions during the periodic “decoking” of fuel cells should be included in the air quality data that are shown, and also sulfur and other contaminants that will eventually be returned to the atmosphere via incineration of hazardous solid waste taken from the desulfurization units.

2. The applications should disclose what will be done with the old fuel cells (total weight is understood to be about 6 million pounds) that are to be removed from the two sites. Unless the old fuel cells are to be sold or recycled, a large volume of electronic waste would need to be disposed of.

3. From the standpoint of Delmarva Power ratepayers, the Qualified Fuel Cell Provider tariff that was approved by the Delaware Public Service Commission in 2011 has represented an extraordinary burden (the “excess cost” borne by ratepayers is over $200 million to date, the total is growing by about $3 million per month, and by its terms the tariff will remain in effect until 2033). Given this background, it seems imperative that the proposed replacement of fuel cells be reviewed in depth by the PSC to ensure that an equitable portion of the economic savings from installing new and technologically improved fuel cells would be applied to reduce the amount of the QFCP tariff that will otherwise be payable by the ratepayers between now and 2033.

Please advise if you have any questions or we can help further.

SAFE

Copies to: Governor John Carney; Shawn M. Garvin, DNREC;
Matt Hartigan, PSC; Andrew C. Slater, Public advocate

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